Not all offerings under Transactional Data Reporting (TDR) are created equal. Two categories, Highly Configurable Products and the Cloud Special Item Number (SIN) 518210C, have unique reporting rules under TDR. These categories require different reporting elements and approaches. In this blog, we’ll cover what TDR is, define Highly Configurable Products and the Cloud SIN, and explain how to navigate TDR reporting for these categories.
Transactional Data Reporting (TDR) is a form of sales reporting incorporated into the General Services Administration Regulation (GSAR) per GSAR 538.270-2. Unlike legacy reporting under Commercial Sales Practices (CSP), TDR does not follow the Price Reductions Clause.
Contractors with one or more eligible TDR SINs must opt their entire contract into TDR, with more SINs slowly being added. The goals of TDR include enhancing market intelligence, increasing price transparency and competition, reducing the burden of Commercial Sales Practices disclosures, and identifying fair and reasonable pricing trends.
As mentioned above, contractors with TDR-eligible SINs must opt-in to TDR. While TDR is available for all product SINs and select service SINs, not all contracts are eligible yet. GSA has made major strides in the past few months to add several SINs to the TDR list, and they plan to add more in the near future. To check eligibility, refer to GSA’s spreadsheet of TDR-eligible SINs.
TDR requires monthly reporting and includes 12 sales data elements across four data groups every month. There are also 4 optional data elements that GSA may make mandatory in the future. For a deeper dive into TDR and its data requirements, see our blog “What is Transactional Data Reporting (TDR)?”
Highly Configurable Products are complex items that require a high degree of customization and are typically assembled from multiple components or options. Due to their variability, these products are not usually listed on GSA Advantage, and they require direct interaction with the customer due to a range of components and customization options. Common examples include modular furniture and workstations, demountable walls, and custom-configured IT hardware or software.
There are currently 68 SINs designated as Highly Configurable. These SINs are awarded under two paths: Path A, which is based on manufacturer product line or family, and Path B, which is based on a base configuration Manufacturer Number (MPN). Contractors can find information about Highly Configurable Products in their Text File or Excel attachment on GSA eLibrary, or in the Services Plus File (SPF) within the FAS Catalog Platform (FCP)
The Cloud SIN includes commercially available cloud computing services (laaS, PaaS, SaaS) and emerging cloud-based AI/ML Solutions. This SIN covers a wide range of offerings such as cloud hosting, computing, and storage services, as well as the development and migration of cloud-native applications. It also includes cloud governance and management services.
Examples of services under the Cloud SIN include SaaS licensing, virtual server capacity, and cloud-based data analytics. Additionally, the SIN includes cloud-related IT professional labor categories, such as migration specialists and security engineers, which support the implementation and maintenance of cloud solutions.
Reporting rules for TDR went into effect on October 1, 2025, and monthly reporting is required starting on that date if your TDR participation modification was approved by September 30, 2025. The first submission deadline for TDR sales reporting is November 30, 2025. April 1, 2026, marks the beginning of regular reporting, and this is when GSA will begin tracking compliance for every report submitted under Path A for Highly Configurable Products and for the Cloud SIN.
If you are reporting sales for Highly Configurable Products under Path A (by manufacturer or family of products), you must provide an invoice, Bill of Materials (BOM), or other supporting documentation for each recorded sale. This documentation must show a breakdown of what was included in each invoice or order. It is recommended that contractors selling Highly Configurable Products begin reporting under Path A and transition to Path B as needed.
For the Cloud SIN, sales must be reported at the transaction level. Each reported order requires an upload of an invoice or BOM. Currently, the service type field for Path A or B has not been implemented, so contractors should include the service type, such as IaaS, PaaS, SaaS, or LCAT, in the description field. Under Path A, an invoice, BOM, or other supporting documentation must be provided with each recorded order.
Below is a breakdown of reporting requirements that differ from standard TDR requirements:
In the Description of Deliverable column:
In the Manufacturer Name column:
In the Manufacturer Part Number (MPN) column:
In the Universal Product Code (UPC) column: Leave blank for all categories
In the Unit of Measure column:
In the Quantity Reporting column:
In the Price Paid Per Unit column: Required for each row; must match awarded UOM.
In the Total Price Paid column: (Quantity × Unit Price); validated upon submission - System-calculated.
Navigating TDR as a contractor can be challenging, especially when additional requirements apply to specific products and SINs. TDR will soon replace Commercial Sales Practices altogether, so it’s best to become familiar with the process now to ensure your contract is ready when it becomes eligible. Our experienced team is here to support your company through a standard TDR transition, as well as transitions involving Highly Configurable Products and the Cloud SIN.